In The Matter Of: 

SERVED: May 18, 2016 

U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, DC 

Docket No. FAA-2015-1319 

WILLIAM A. CURTRIGHT 

) 

) 

) 

) 

) 

Case No. 2014NM090046 

Respondent 

ORDER FINDING GOOD CAUSE FOR THE RESPONDENT'S 

UNTIMELY ANSWER, DENYING THE FAA'S RENEWED MOTION, 

AND GRANTING/DENYING OTHER RELIEF 

On May 27,2015, the FAA's Complaint (dated May 19, 2015) was filed with the Office 

of Hearings. 

Approximately twelve (12) days later, on July 8, 2015, Judge Goodwin issued a 

Procedural Order in which the parties were directed to complete discovery by December 4, 2015, 

and be ready to present the case for hearing on or after that date. (July 8, 2015 Order, 2 ,-r,-r 2-3.) 

On August 5, 2015, the FAA filed the Complainant's Motion to Deem Allegations 

Admitted and to Dismiss Appeal ("Motion"). 

That same day, on August 5, 2015, the prose Respondent, Mr. William A. Curtright, 

filed a Response to the Complaint ("Answer"). Included in this Answer was an untitled Motion 

to deem the case resolved, and to dismiss the proposed civil penalty of $11,000. ("August 5, 

20 15 Motion") 1 

1 The Respondent did not file a Certificate of Service with his Answer and untitled Motion to Dismiss. The Answer 

included an assertion that it had been sent to the FAA attorney ("cc by email"), but there was no confirmation, 

pursuant to 14 C.F.R. § 13.211, that the Answer had also been filed with the FAA Hearing Docket. (Ans. 2.) 

. : ·,,,. 
Six (6) days later, on August 11, 2015, the prose Respondent filed a Reply to 

Complainant's Motion to Deem Allegations Admitted and to Dismiss Appeal ("Response").2 

On September 4, 2015, Judge Goodwin transferred to a different agency. At the time of 

this transfer, no hearing date had been set, and the motions previously filed remained pending. 

On October 8, 2015, an Order Reassigning Proceeding was filed, which reassigned the 

case to the undersigned. 

On October 15, 2015, the FAA filed Complainant's Renewed Motion to Deem 

Allegations Admitted and to Dismiss Appeal ("Renewed Motion"). 3 

On October 21, 2015, an Order Setting Deadlines for the FAA to Supplement Its Motion, 

for the Respondent to Respond and Show Cause, and Granting/Reserving Other Relief was filed. 

Pursuant to the October 21, 2015 Order, on October 29, 2015, the FAA filed the 

Complainant's Supplemental Pleading to its Renewed Motion ("Supplemental Pleading"). 

On November 17, 2015, the Respondent filed its Reply [sic] to Order Setting Deadlines 

for the FAA to Supplement Its Motion, for the Respondent to Respond and Show Cause, and 

Granting/Reserving Other Relief ("Show Cause Statement").4 

On November 19, 2015, an Order Setting Deadlines for the FAA to File a Response, the 

Respondent to File a Reply, and Reserving Other Relief was filed. 

2 A "reply" is a final argument filed by a moving party, after the opposing party has filed a response to any motion 

made by the moving party. The prose Respondent's August 11, 2015 material, although titled as a "Reply," is 

actually a Response to the FAA's August 5, 2015 Motion. It should also be noted that the record does not reflect 

that the prose Respondent filed his Response with the FAA Hearing Docket, pursuant to 14 C.F.R. § 13.211. See, 

Resp., Cert. of Service. 

3 This October 15, 2015 Renewed Motion superceded the August 5, 2015 Motion. The FAA's October 15, 2015 

Renewed Motion was filed pursuant to 14 C.F.R. § 13.218(f)(5), which allows a party to file a Motion for Decision 

based on the record. However, the October 15, 2015 Renewed Motion was identical to the original August 5, 2015 

Motion, except for the signature dates and updated dates of pleading. Thus, the FAA's October 15, 2015 Renewed 

Motion supersedes it's earlier filed August 5, 2015 Motion. 

4 As noted in Fn. 2, supra, a "reply" is a final argument filed by the moving party after the opposing litigant has filed 

a response. In contrast, the Court is not a litigant or party to the action. If the Court issues a ruling and invites or 

directs a litigant to supplement the record, such supplemental material is titled as directed by the Court Order (e.g., 

"Show Cause Statement") 

Page 2 of 11 
On December 4, 2015, the FAA filed the Complainant's Response to the ALJ's Order of 

November 19, 2015 ("Response to Show Cause"). 5 That same day, the FAA filed a signed 

Complaint. 

On January 6, 2016, the Respondent filed its Reply to Complainant's Response to the 

AU's Order.ofNovember 19,2015 ("Reply"). 

On January 19, 2016, the Respondent filed a Motion to Dismiss ("Second Motion to 

Dismiss"). 

A. Issues 

This Order addresses only the FAA's Renewed Motion to Dismiss.6 The issues are 

whether the pro se Respondent's August 5, 2015 Answer was timely and, if not, whether good 

cause exists for that untimeliness. 

B. FAA Rules of Practice - Timely Answer or Good Cause Showing Required 

The FAA's Rules of Practice require a respondent to file a timely answer after service of 

the FAA's complaint. 14 C.F.R. § 13.209. At the most, a responding party has 35 days to file a 

timely answer after service of a Complaint. 7 If an answer is filed beyond the 3 5 day period, the 

responding party who has filed a late answer to a Complaint may petition for relief from a 

default action. Pursuant to 14 C.F.R. § 13.209(£), in support of its request for relief from a 

default action, the responding party must demonstrate good cause. "A showing of good cause is 

mandatory. Without it failure to file an answer by the deadline may not be excused."' Global 

5 The FAA was invited by the Court to file a Response to the arguments made by the Respondent in his Show Cause 

Statement (Nov. 19,2015 Order, 2 ~ 1.) As already discussed above (See Fns. 2 and 4, supra), the Court is not a 

party to the action. The directives in a Court Order are not party arguments. Thus, a litigant does not file 

"responses" or "replies" to a Court Order. 

6 The Respondent's January 19, 20 I 6 Motion to Dismiss, as well as those portions of his August 5, 20 I 5 Motion and 

January 6, 2016 Reply that also move for dismissal on similar grounds, will be addressed by a separate order. 

7 Pursuant to 14 C.F.R. § l3.209(a), a respondent is allowed 30 days after service of the complaint to file a written 

answer to the complaint Pursuant to 14 C.F.R. § 13.2 I I (e), five additional days are added to the 30 day time period 

whenever a complaint is served by mail. Pursuant to 14 C.F.R. § 13.212(b ), the date of service is not included in the 

calculation oftime. 

Page 3 of 11 
Peace Initiative, Inc., FAA Order No. 2008-8 at 6 (Aug. 21, 2008) (quoting Atlantic World 

Airways, FAA Order No. 1995-28 at 4 (Dec. 19, 1995). 

Good cause is a "nebulous" standard. See, 21A Fed. Proc. L. Ed.§ 51:64 (2014). It is an 

evaluation that rests within the discretion of the trial court, since there is a preference for 

deciding cases on their merits. 1 OA Charles Alan Wright & Arthur R. Miller, Fed. Prac. & Proc. 

Civ. § 2693 (3d ed. 2014 ); See, e.g., In re David Lloyd Cornwall, FAA Order No. 92-4 7 at 7 

(July 22, 1992) (Wherever possible, cases should be heard "on the merits"). In evaluating good 

cause, there is "no fixed, rigid standard" that can anticipate "all the situations" which might arise 

for a party's failure to file a timely answer. 21A Karl Oakes, Fed. Proc. L. Ed. §51 :64 (20 14). 

Therefore, in determining whether good cause exists or does not exist, the court may consider the 

nature of the default, whether there is a meritorious defense, whether the opposing party will be 

prejudiced, the timeliness of the request for relief, the amount involved in the litigation, as well 

as the availability and effectiveness of less drastic solutions. 29 A.L.R. Fed. 7, Good Cause 

General Considerations, §4 (1976). Other considerations in evaluating good cause (not 

inclusive) may include the inaction of a party's counsel, a party's mistaken ~elief about the time 

requirements, the willfulness ofthe party's non-compliance, any factors demonstrating excusable 

neglect, surprise, or inadvertence, or a party's erroneous reliance on settlement negotiations. 29 

A.L.R. Fed. 7, Sufficiency of Particular Reasons for Inaction,§§ A and B (1976), See also, Edes 

v. Fredson, 344 F. Supp. 2d 209 (D. Me. 2004). 

C. Summary of Parties' Arguments 

1. FAA's Renewed Motion and Supplemental Pleading 

In its October 15,2015 Renewed Motion and its October 29,2015 Supplemental 

Pleading, the FAA asserts that it served the Respondent with its Complaint on May 19, 2015 by 

certified mail, to Mr. Curtright's post office box address: P.O. Box 1350, Jefferson, OR 97352. 

(Supp. Plg, Att. 1.) The Complaint was signed for by a Dana Curtright on May 22, 2015. (!d.) 

The FAA argues that the Respondent's May 11, 2015 Request for Hearing ("Request") 

should be dismissed, on the grounds that the Respondent was served on May 19,2015, and failed 

to file a timely answer to the Complaint. According to the FAA's time calculations, the 

Respondent's answer was due on or before June 23, 2015. (Supp. Pig., 1.) The FAA also asserts 

Page 4 of 11 
that it gave the Respondent "specific" notice of the requirement to file an answer within thirty 

(30) days. 

2. Respondent's Show Cause Statement 

The record shows that the pro se Respondent, Mr. Curtright, filed an Answer on August 

·5, 2015, the same day the FAA filed its Renewed Motion. In his November 17, 2015 Show 

Cause Statement, Mr. Curtright did not dispute that he had been served a copy of the Complaint 

by certified mail on May 19, 2015. He did not address the FAA's assertion that a timely Answer 

to such Complaint, if valid, should have been a filed on or before June 23, 2015. (Show Cause 

Stmt. 1- 2.); 14 C.F.R. § 13.209(a). Mr. Curtright explained, however, that the May 19,2015 

Complaint had not been signed by the FAA attorney. He thought a signature on legal documents 

was required; otherwise, the document was not "formal" and did not require a response. (!d. at 

1.) Mr. Curtright also noted he was not an attorney. He had "inadvertently missed" the FAA's 

warning language attached to the Complaint, in part because it was a separate page following the 

end ofthe Complaint. (!d) 

3. FAA's Response to Show Cause 

As outlined earlier herein, upon receipt of the Respondent's materials, a November 19, 

2015 Order was filed. This November 19, 2015 Order allowed both the FAA to respond to the 

prose Respondent's Show Cause argument regarding the unsigned Complaint, and the 

Respondent to file a Reply. (November 19,2015 Order, 2 ~ 1.) 

In its December 4, 2015 Response to Show Cause, the FAA presented several 

arguments. First, the unsigned Complaint was not a fatal error that invalidated the Complaint. 

Instead, it was a "minor procedural defect" that did not excuse the Respondent's failure to file an 

Answer. (FAA Resp. to Show Cause at 1.) Second, the FAA counsel's signature on the cover 

letter to the Complaint,8 as well as the FAA clerical employee's signature on the Certificate of 

Service, left "no question but that the FAA intended to file a Complaint in this matter." (FAA 

Resp., 2.) Third, the FAA argued that the FAA Administrator has consistently rejected "the 

notion thatpro se respondents should not be held to a standard of compliance." (!d. (citing 

8 A copy of the FAA's May 19, 20 16 Cover Letter is attached as an unmarked exhibit to the FAA's December 4, 

20 15 Response. 

Page 5 of 11 
Barbera, FAA Order No. 2015-4 (Sept. 9, 2015))). Thus, the Respondent's assertion that he did 

not understand the requirement to comply with 14 C.F.R. § 13.209 by filing an answer to the 

Complaint should not be accepted as good cause. (FAA Resp. 2.) 

4. Respondent's Reply 

In his January 6, 2016 Reply, Mr. Curtright also presented several arguments. First, the 

FAA should not have it both ways: on one hand arguing that the Respondent's Request should be 

dismissed for failure to comply with the procedural requirements, while on the other hand, 

arguing that the FAA's failure to meet procedural requirements by serving and filing an unsigned 

Complaint should be deemed to have no effect on the proceeding. (Reply 2.) Second, the FAA's 

cited authority in support of its contention that a missing signature was a minor procedural defect 

was inapposite, because the Complaint was not a Judicial Order as discussed by the cited 

authority. (!d. at 2.) Lastly, Mr. Curtright argued that the timeliness rule appeared to be a "secret 

standard of compliance" favoring the FAA, who is a party to the litigation. (!d.) He objected to 

being held to such a rule, on the grounds of unfairness. (!d.) 

D. Discussion 

All pleading and arguments submitted by both parties were fully considered. However, 

only certain matters will be highlighted in this discussion. 

1. Signature on Pleading Required 

In support of its Renewed Motion, the FAA argues, in part, that the Respondent should 

have known the Complaint was official, because the accompanying Cover Letter was signed by 

counsel, and the Certificate of Service was signed by an FAA employee. (FAA Resp., 2.) This is 

not persuasive. Section 13.207(a) requires a party or attorney representative to sign each 

documents/he files or serves. This signature acts as a certification that the document's contents 

are warranted by law and are consistent with the FAA's Rules ofPractice. 14 C.F.R. § 

13 .207(b ). If documents are signed in violation of the Rules of Practice, sanctions may be 

imposed. 14 C.F.R. § 13.207(c). Thus, the fact that counsel's signature was affixed to a Cover 

Letter addressed to the Hearing Docket Clerk may not qualify as a "substitute" for the required 

party or attorney representative certification of the pleadings. 

Page 6 of 11 
2. The Validity of Unsigned Complaint 

Although Section 13.207 does not specifically address the effect of failing to sign a 

document, Federal Rule of Civil Procedure 11 (a) provides instructional guidance. Rule 11 (a) 

states, in part: "The court must strike an unsigned paper unless the omission is promptly 

corrected after being called to the attorney's or party's attention." Fed. R. Civ. P. 11(a). 

In the instant case, the FAA was unaware of its non-compliance with 14 C.F.R 

§ 13.207(a) until November 17,2015, when the prose Respondent filed his Show Cause 

Statement and brought the omittecrslgnature on the Complaint to the FAA's attention. (Show 

Cause Stmt. 1.) Seventeen (17) <;lays later, on December 4, 2015, the FAA's Response to Show ' \. : ~. . . 

Cause was filed, which includeq \\.~igned version ofthe May 19, 2015 Complaint. (FAA Resp. 1, ~ : / i : \ 

Attach.) This was a prompt acti9Nl:~ince it occurred prior to the December 15, 2015 deadline set 

by the Court for the FAA to fil~ a ~esponse. (Nov. 19, 2015 Order 2.) ' ' 

Federal courts have held Jh(l-t if an unsigned document is "promptly corrected" pursuant 

to Rule ll(a), then the unsigned <;iQcpment is considered to be "filed" on the date it was filed l'l. 

with the clerk. See Becker v. Mqntgomery, 532 U.S. 757 (2001); IRS v. Koff, No. S-00-CV-1954, ·::.:'!. ',. 

2002 WL 1004744, at *6 (E.D~ G,al. Mar. 18, 2002) (action is "commenced" by filing unsigned . ', :\. ·. 

complaint). In this case, since the FAA promptly corrected the omission on December 4, 2015, : ''.1 

its Complaint is considered to b~ 'validly filed with the FAA Hearing Docket and served on the ·. ,,· 

Respondent on May 19, 2015, even though it was unsigned at the time of filing and service. 

3. Respondent's August 5, 2015 Answer- Untimely 

Because the FAA's Complaint is deemed to have been validly filed and served on May 

19, 2015, the due date for a tim.ely answer to the Complaint was June 23, 2015. As a result, the 

Respondent's Answer, filed on August 5, 2015, was untimely. 

4. Respondent Has Demonstrated Good Cause 

The FAA Administrator has held that good cause may be found when an FAA attorney, 

albeit inadvertently, misleads a respondent regarding the requirement to file an answer. See 

Sutton, FAA Order No. 1994-20, at 4 (Sept. 30, 1994) ("If communications between Respondent 

and the agency attorney ... led Respondent reasonably, but incorrectly, to believe that 

Page 7 of 11 
submitting [an answer was unnecessary], then in the interest of fairness, good cause may be 

found .... "). 

In the instant case, the benefit of the doubt should be given to the prose Respondent, in 

considering whether the lack of a signed Complaint "reasonably" misled the Respondent to 

believe that the Complaint was an informal document requiring no answer. The Respondent 

filed his Answer on August 5, 2015, four (4) months prior to the FAA filing a signed copy of the 

Complaint on December 4, 2015 (i.e., seventeen (17) days after the prose Respondent filed his 

November 17,2015 Show Cause Statement identifying the signature omission). ;,. ,' ' 

The "interest of fairness" emphasized by the FAA Administrator in Sutton would not be 

served by a ruling that the FAA's mistaken failure to comply with the Rules of Practice can be ~ i i 

cured by promptly correcting the f~ilure, while the Respondent's failure to comply with the 

Rules, which was caused at least in part by the FAA's failure to comply, must result in the 

Respondent losing his opportun.i\Y. for a hearing and a decision on the merits. 

5. "Specific" Warning Language 

The FAA argued that it had provided "specific" warning to the Respondent about the 

need to file a timely answer. This· should be briefly addressed, since it is often a source of 

dispute between the parties in civil penalty enforcement adjudications. As noted by the 

Respondent herein, the FAA's Wf!.Ining language 9 appeared on a page separate from the 

Complaint. 10 The Respondent overlooked it because he did not understand what the attachment 

was and why it might be so important. This appears to be fairly common response by pro se 

claimants. In addition, this Court would note that the "warning" paragraph in this particular case 

is entitled as "ANSWER", but if one reads the paragraph, it is not an Answer at all. Instead, it is 

a statement that an answer has not yet been filed, and a warning that a time-sensitive action (i.e., 

the "clock" is ticking) needs to be taken on the matter. While this Court understands that the 

9 The language contained on the attached document stated: "ANSWER In accordance with Section 13.209 of the 

Federal Aviation Regulations, William A. Curtright, must answer this Complaint not later than thirty (30) days from 

the time it is served. Failure to file an Answer within thirty (30) days without good cause shall be deemed an 

admission ofthe truth of each allegation contained in the Complaint [14. [sic] C.F.R. § 13.209(f)]." (Comp. Att.) 

10 NB: The placement of the FAA's warning language varies, depending on which regional office is prosecuting the 

action. For example, other FAA Complaints have included the warning in the Complaint itself, immediately above 

or below the FAA attorney's signature line. 

Page 8 of 11 
. 

FAA has utilized "Answer" as the warning heading for many years, it appears to be misleading. 

A more accurate warning heading, with placement of the warning language above counsel's 

signature in the pleadings, might prove more effective. 

6. The FAA's Public Rulemaking and Rules of Practice 

The Respondent's arguments that the rules governing this proceeding are a "secret 

standard of compliance" and that "[t]he FAA does not get to decide the rules when the FAA is 

one party in a dispute" (Reply to Order 2) also needs to be briefly addressed. 

'IL.' \\ . 

There is no doubt that r~~pot;Iding to any legal proceeding takes hard work, attention and ,1 11 if.-..• 1, 

time, even for experienced lawyers. When one is not a lawyer, unused to legal terms, procedures, .. ,:·. P''l·· 

and research, it can take even more effort and hard work. But just because something is difficult 

or new, particularly within a speci:afty field such law and aviation safety, does not mean that the 

standards or rules within such a specialty field are wrong, secret, or unfair . . li\. i':,. 

First, the FAA was suppbsdd to create the rules for FAA civil penalty proceedings. 

Congress specifically delegated :Suth authority to the FAA Administrator. See 49 U.S.C. § 

46301(d)(2), (7)(A) (2014). As\·P;~ ofthat delegated authority, the FAA Administrator spent 

considerable time arid attentiorftb promulgate procedural rules governing FAA civil penalty ·. \ 't' {''·, . 

proceedings that would be fair i6 everyone. II The FAA Administrator's discussion about the 'l•:f'' 

creation of the rules, as well as hjs,responses to members of the public who commented on what ;';:'·:':·;: 

should be included (or omitted) is not a secret. Rather, it has been published and available to the '."\•, . 

public for twenty-six (26) years'.55 Fed. Reg. 27548 (Jul. 3, 1990) (Discussion of Final Rule). 

The Respondent's assertions of"secrecy" are simply incorrect, and likely result from the :·, 

Respondent's unfamiliarity with_this area ofthe law. In fact, the FAA's Rules of Practice are i• :·. 

available to any member of the pJbilc. They are published in both the Federal Register and in .... I'· 

11 To help ensure fairness, the FAA Adn1inistrator is prohibited from being a party litigant to these proceedings. 14 

C.F.R. § 13.203. During the litigation, the FAA Regional Counsel, through the designated agency attorney, is the 

complainant in this proceeding and is prohibited from "participat[ing] or giv[ing] advice in a decision by the 

administrative law judge or by the FAA [Administrator] on appeal, except as counsel or a witness in the public 

proceeding." 14 C.F.R. § 13.203(b); see also, 5 U.S.C. § 554(d)(2). The FAA Administrator only becomes involved 

if either party appeals the decision ofth~ undersigned Judge. 14 C.F.R. § 13.233. 

Page 9 of 11 
the Code ofFederal Regulations (see 14 C.F.R. Part 13, Subpart G). 12 Additionally, the 

decisions and orders of the FAA Administrator applying the Rules of Practice are also available 

to the public. 13 

E. Conclusion 

Based on the foregoing, and having reviewed all pleadings and documents, as well as all 

relevant caselaw, decisions, regulation, statutory authority, and being fully advised; 

, i L'. ~ ·..;.\..·(,: 

IT IS HEREBY ORDERED: ... \ .l\. i:' 

l. The FAA's August 5, 2015 Motion was superseded by the FAA's October 15,2015 

Renewed Motion. The August 5, 2015 Motion is deemed moot. 

2. The FAA's Complaint, signed and filed on December 4, 2015, is deemed valid as May 

19,2015. 

3. The prose Respondent's August 5, 2015 Answer was untimely . 

. ,' 1. ,;• 

4. The Respondent has showri good cause for its untimely August 5, 2015 Answer. 

' ' ·,u 

5. The Respondent's untim.'e1y August 5, 2015 Answer is accepted. 

:.•! 

6. The FAA's October 15, 2015 Renewed Motion is denied. 

7. A separate order will issue on the Respondent's January 19,2016 Motion to Dismiss. 

·.·,·. 

12 There are multiple public and commercial resources available to find and use these sources. For example, the 

U.S. Government Publishing Office's Federal Digital System is available at https://www.gpo.gov/fdsys/pkg/CFR20 IS-title 14-voll /pdf/CFR-20 IS-title 14-voll-part 13-subpartG.pdf. 

The Federal Aviation Administration's website is available at 

http://www.faa.gov/aboutloffice erg/headquarters offices/age/pol adjudication/agc400/civil penalty/Rules/mediald 

sp RulesofPrac.pdf. 

13 Federal Aviation Administration website, available at 

http://www. faa.gov /about/office_ orglheadquarters _ offices/agc/po I_ adj udication/agc400/civi !_penalty I 

Page 10 of 11 
8. If either party needs clarification or has any questions regarding the procedures contained 

in this Order, contact Mr. Cody L. Smith, Attorney-Advisor at the Office of Hearings 

(202-366-6941 ). 

Attachment: Service List 

l!. t ( \' 

1'1, 

Page 11 of 11 
Docket No. FAA-2015-1319 

(Civil Penalty Action) 

SERVICE LIST- BY U.S. MAIL 

ORIGINAL & ONE COPY 

Federal Aviation Administration 

800 Independence Avenue, S.W. 

Washington, DC 20591 

Attention: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building-Suite 2Wl0001 

Mr. David F. Shayne 

Complainant's Counsel ·~ i!' · 

Northwest Mountain Region, ANM-7 

Federal Aviation Administration 

1601 Lind Avenue S.W. 

Renton, W A 98057 

TEL: 425-227-1847 

FAX: 425-227-1007 

,, 

Dr. William Ames Curtright, D~.~ " . 

Respondent '· · 

P.O. Box 1350 

Jefferson, OR 97352 

Judge J.E. Sullivan 

U.S. Administrative Law Judge 

Office of Hearings, M-20 

' .~ ' · .. :,• 

U.S. Department ofTransportation 

1200 New Jersey Avenue, S.E. (Ell-310) 

Washington, DC 20590 

TEL: 202-366-6941 

FAX: 202-366-7536 

ONE COPY 

1 Service was by U.S. Mail. For service in person or by expedited courier, use the following address: Federal 

Aviation Administration, 600 Independence Avenue, S.W., Wilbur Wright Building-Suite 2WIOOO, Washington, 

DC 20591; Attention: Hearing Docket Clerk, AGC-430.